>OSHA is in the beginning stages of drafting yet another new rule. The Injury and Illness Prevention Program or I2P2 would be a rule that requires businesses to provide a safety program that is specifically tailored to the hazards onsite and has certain criteria that each program must meet.
This idea has been around for a long time and was last brought up several years ago. We, honestly thought the issue was dead but has gained new life recently. The OSH Act (Law) already says employers must provide a safe workplace. That law is known as Sec. 5(a)1 or the “General Duty Clause”. “…employers must provide a workplace that is free from recognized hazards that are causing or likely to cause death or serious physical harm…” This clause is a catch all that many gins are already familiar with.
The General Duty Clause is used any time a specific OSHA standard doesn’t directly apply but someone still got hurt. It hasn’t been used as a catch-all for general inspections until recently. Nevertheless, OSHA is beginning to gather information to draft a new catch-all type rule to require a safety or I2P2 program for employers. This could likely end up being just more piling on for citations.
Do we think safety programs are important? SAFETY PROGRAMS ARE EXTREMELY IMPORTANT. The best way to prevent accidents is to develop a comprehensive program that inventories all hazards and eliminates the hazard or eliminates exposure to the hazard. That is already implied in current law and new law is not necessary in my opinion.
Southeastern Cotton Ginners, as do most of the other ginner associations, already has a very good safety program that is easily adapted to your operation. We’re happy to work with you in implementing it at your facility we just don’t want another way for OSHA to write our members up if they don’t cross every T and dot every “i”.